Two countries, one structure. In both Morocco and Tunisia the currency is managed and cross border transfers by residents are governed by an exchange control code administered by the state, separately from whatever the capital markets regulator does. A resident cannot simply wire money abroad to open a margin account. The permitted purposes are enumerated, the allowances are administered, and moving currency outside that framework is an offence rather than a grey area.
Founders who have worked in Europe find this counterintuitive. In the European Union the licensing question is the hard part and payments follow. Here the payments question is the hard part and licensing is almost secondary, because the client cannot legally fund the account you are proposing to open for them.
Morocco: the Office des Changes sits above everything
Morocco's capital market regulator is the Autorité Marocaine du Marché des Capitaux, which supervises the Casablanca exchange, listed issuers, collective investment schemes, and the intermediaries operating in the market. Bank Al-Maghrib is the central bank and supervises credit institutions and payment institutions.
The exchange control regime is administered by the Office des Changes, which sets out what residents may transfer abroad and for which purposes. Allowances exist for travel, education, certain business needs and defined categories of foreign investment, each with its own conditions and documentation. Speculative margin trading with a foreign counterparty is not among the categories a bank will process routinely, and the Office has publicly cautioned residents about online trading platforms soliciting them.
Casablanca Finance City is the exception that proves the structure. It is a special status regime with its own tax and, importantly, its own exchange treatment for qualifying entities serving non resident business. It is designed for firms exporting services outward, not for firms collecting money from Moroccan retail clients. Reading it as a back door into the domestic market misunderstands what it exists to do.
Tunisia: the Code des Changes and a non convertible dinar
Tunisia's securities regulator is the Conseil du Marché Financier, which supervises the Tunis exchange, listed companies, collective schemes and market intermediaries. The Banque Centrale de Tunisie administers the Code des Changes.
The dinar is not convertible for capital account purposes and its physical export is prohibited. Outbound transfers by residents are permitted only for enumerated purposes and through authorised intermediaries. Tunisia has an established enforcement history around currency offences, and the exposure sits with the resident sending the money as well as with anyone facilitating it. This is the country where the phrase "real consequences" is not a rhetorical softener.
Tunisia also operates a non resident company regime aimed at export oriented activity, which is sometimes marketed to founders as a way to base an operation there. As with Casablanca Finance City, the regime is built for serving clients outside the country. It does not create a route to the domestic retail market.
This article is descriptive general information, not legal advice. Rules and public notices change. Any firm dealing with Moroccan or Tunisian clients must take its own qualified legal advice in the country concerned before it markets, onboards or takes a payment. Leveraged trading carries a high risk of loss.
What this does to payments and banking
The mechanisms that decide whether you can take this business are the same ones described everywhere else in this series, applied to a stricter fact pattern.
- An acquirer looking at cards issued in a country with capital controls will weigh the possibility that the underlying transaction is not permitted for the cardholder, which is a chargeback and regulatory exposure rather than merely a credit one.
- A correspondent bank applies country risk ratings that account for exchange control regimes, sanctions proximity and monitoring status across the region.
- Local banks are the enforcement point for the exchange code. They ask for the purpose, they ask for supporting documents, and refusing an unsupported transfer is their obligation rather than their preference.
- Payment providers running periodic merchant review will treat inbound flow from restricted currency jurisdictions as a flag, particularly where the declared merchant category does not match the observed pattern.
The predictable result is that money from these markets reaches offshore firms through channels that leave no clean audit trail: cash carried out, third party accounts abroad, informal transfer networks, stablecoins bought locally. Every one of those creates a source of funds problem for the receiving firm, and our note on screening and diligence basics explains why the receiving firm cannot simply say it did not know.
The IBAN question and the diaspora market
There is a legitimate market here, and it is not the resident retail client. Moroccan and Tunisian nationals living in France, Belgium, Italy, Spain, Canada and the Gulf are resident where they live and are governed by that country's rules. They hold local bank accounts, they can be onboarded properly, and they are a substantial diaspora with genuine demand for financial services in Arabic and French.
Serving them means being authorised where they live. A European client base means a European route, and the honest position is that for a firm serving EU residents no offshore registration works. If a firm tries to serve a French resident from an offshore entity it also runs into practical payment friction, including the refusal of foreign accounts that our piece on IBAN discrimination covers, and a reverse solicitation argument that regulators have narrowed considerably.
How to approach the region honestly
If your target is the domestic Moroccan or Tunisian retail client, get local counsel to tell you what a resident may lawfully do with their money before you plan anything else. If the answer is that they cannot fund a foreign margin account, then you do not have a licensing project, you have a market access problem that no licence solves.
If your target is the diaspora, licence where those clients live and market to them there in their language. That is a slower and more expensive business to build, and it is one that a bank will actually hold an account for. We supply the software for either version, and our comparison of regulated and unregulated operations sets out how differently the two run day to day.
"People ask me which North African licence to get. In Morocco and Tunisia the exchange control office is the regulator that will decide your business, and it does not issue broker licences."
— Alex Onta, Executive Director, SINGUARD
Key Takeaways
- The dirham and the dinar are not freely convertible; outbound transfers by residents are limited to enumerated purposes under exchange control codes.
- The AMMC and the CMF supervise their domestic capital markets, but the exchange control administrators decide whether client money can reach a foreign broker at all.
- Casablanca Finance City and Tunisia's non resident regimes are built for serving clients outside the country, not for reaching domestic retail.
- The realistic addressable market is the diaspora, served under the rules of the country where those clients actually live.
Frequently Asked Questions
Is retail forex trading with a foreign broker legal in Morocco?
The Office des Changes administers what Moroccan residents may transfer abroad and for which purposes, and speculative margin trading with a foreign counterparty is not among the categories a bank processes routinely. The Office has cautioned residents publicly about online trading solicitation. Anyone considering this needs Moroccan legal advice on their own situation.
Can a firm base itself in Casablanca Finance City to serve Moroccan clients?
The regime is designed for entities providing services to non resident business, with tax and exchange treatment built around that purpose. It is not a route into the domestic retail market, and treating it as one misreads both the status conditions and the exchange control regime that continues to apply to residents.
What about Moroccan and Tunisian nationals living in Europe?
They are resident where they live and governed by that country's rules, which for the European Union means the MiFID framework and national conduct requirements. Serving them lawfully means being authorised in the European Union rather than offshore. Reverse solicitation has been narrowed by regulators and is not a business model.
About the Author
Alex Onta is an Executive Director at SINGUARD. He built eTrader, the terminal, the mobile apps, eTrader Broker, Copytrading, Business and Community, along with the worldwide clustered-server infrastructure it all runs on, with his brother Roman Onta helping on the design, and he leads that division today. Together with Roman he builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals, and the two of them carry worldwide compliance, payment processing and international business structuring side by side. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.